Case Digest (G.R. No. L-25422)
Facts:
The case involves Juan Amansec, represented by his heirs—Amelia, Soledad, Rosauro, and Rosalinda Amansec—who are the plaintiffs-appellants, and Angel Melendez, Maria Alcaide, the heirs of Florentino Amansec, and the heirs of Vicente Amansec, who are the defendants-appellees. The events leading to this case began with the issuance of Original Certificates of Title Nos. 67800 and 67870 to the defendants, Melendez and Alcaide, following a decree of registration entered in Land Registration Case No. 16678 on October 3, 1941. The plaintiffs filed their complaint for reconveyance on March 20, 1965, alleging that the properties in question were fraudulently disposed of by Florentino Amansec, who conspired with the heirs of Vicente Amansec to misrepresent the ownership of the land. The plaintiffs claimed that the defendants were aware that the true owner was Juan Amansec, who had passed away two years prior to the fraudulent transaction. The defendants...
Case Digest (G.R. No. L-25422)
Facts:
Parties Involved:
- Plaintiffs-Appellants: Heirs of Juan Amansec (Amelia, Soledad, Rosauro, and Rosalinda Amansec).
- Defendants-Appellees: Angel Melendez, Maria Alcaide, the heirs of Florentino Amansec, the heirs of Vicente Amansec, Sofia @ Pia Amansec, and Cipriana Amansec.
Subject Property:
- Two parcels of land covered by Original Certificates of Title Nos. 67800 and 67870, registered in the names of Angel Melendez and Maria Alcaide.
Allegations of Fraud:
- The plaintiffs alleged that Florentino Amansec, in conspiracy with the heirs of Vicente Amansec, fraudulently transferred the properties to himself, falsely representing that the lands belonged to Vicente Amansec.
- Florentino Amansec then sold the properties to Angel Melendez and Maria Alcaide, who allegedly knew that the lands rightfully belonged to Juan Amansec.
- The plaintiffs claimed that the defendants fraudulently excluded the heirs of Juan Amansec from the registration process, despite knowing that Juan Amansec was the true owner.
Timeline of Events:
- The decree of registration was issued on October 3, 1941.
- The plaintiffs filed their complaint for reconveyance on March 20, 1965, nearly 24 years after the issuance of the decree.
- The plaintiffs claimed they discovered the fraud only in 1964.
Procedural History:
- The trial court dismissed the case on the ground of prescription, ruling that the action had already prescribed.
Issue:
- (Unlock)
Ruling:
- (Unlock)
Ratio:
Prescriptive Period for Reconveyance:
- An action for reconveyance based on implied or constructive trust prescribes within ten (10) years from the issuance of the title.
- The issuance of the title constitutes constructive notice to the public, including the plaintiffs.
Counting the Prescriptive Period:
- The prescriptive period begins to run from the date of the issuance of the title, not from the date of discovery of the fraud.
- In this case, the decree of registration was issued on October 3, 1941, and the plaintiffs filed their complaint on March 20, 1965, which was well beyond the ten-year prescriptive period.
Applicable Law:
- The Court cited previous jurisprudence, including Gerona vs. De Guzman and De la Cerna vs. De la Cerna, which established that the prescriptive period for reconveyance is ten years from the issuance of the title.
Conclusion:
- The plaintiffs' cause of action arose on the date the title was issued, and their failure to file the action within the ten-year prescriptive period barred their claim.
Additional Observation
Justice Abad Santos noted that the applicable statute is Act No. 190, which governs the prescriptive period for actions.